Where a U.S. District Court judge dismissed a plaintiff's disability discrimination complaint against the defendant Department of Veterans Affairs due to her concession that she failed to timely file a formal complaint with the Equal Employment Opportunity Commission, the judge did not abuse his discretion by declining to toll the limitations period.

Where a plaintiff filed suit under the Employee Retirement Income Security Act for long-term disability benefits under the defendant employer’s plan, an order dismissing the complaint on timeliness grounds must be reversed according to the doctrine of equitable tolling.